Sub-Recipient Monitoring Policy

Background

The Office of Management and Budget (OMB) Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, Final Rule, 2 CFR 200, Dec. 26, 2014, ("Uniform Guidance") sets forth standards for obtaining consistency and uniformity in organizations expending Federal awards. In instances where the award recipient subcontracts with another organization to perform duties required or necessitated by the research award, the award recipient is considered to be a pass-through entity. As a pass-through entity, the award recipient has monitoring obligations to ensure that the sub-recipient uses the award for authorized purposes and that the goals of the award are achieved.

Purpose

The purpose of this policy is to define subawards, identify roles and responsibilities for those requiring subrecipient monitoring, and provide guidance in fulfilling those responsibilities for grants and sponsored projects.

Definitions

A "subrecipient" is the legal entity to which a subaward is made and which is accountable to Davidson College for the use of the funds provided in carrying out a portion of the programmatic effort under a sponsored project.

A "subaward" is an award of financial support from Davidson College ("prime recipient") to a qualified organization for the performance of a substantive portion of the program funded under the prime award. It does not include procurement of goods and services funded by a prime award, i.e., vendors are not considered subrecipients.

Policy

In accordance with Uniform Guidance 200.331, as a pass-through entity, Davidson College will ensure the following as it relates to the subrecipients of federal funds.

A. Ensure that every subaward is clearly identified to the subrecipient as a subaward and includes the following information:

Federal Award Identification

Subrecipient Name (must match the DUNS number)

Subrecipient DUNS number

Federal Award Identification Number (FAIN)

Federal Award Date

Sub-award Period of Performance Start and End Date

Amount of Federal Funds obligated by this action

Total Amount of Federal Funds Obligated to the subrecipient

Total Amount of the Federal Award

Federal Award Project Description

Name of Federal Awarding Agency

Name of Pass-Through Entity (Davidson College)

Contact information for awarding official

CFDA Number and Name

Identification of whether the award is R&D

Indirect Cost Rate for the Federal Award

Flow-down requirements imposed on subrecipient

Any additional requirements imposed on subrecipient

Subrecipient's federally-negotiated indirect cost rate agreement

A requirement that the subrecipient permit Davidson College auditors access to the subrecipient's records and financial statements as necessary for audit requirements.